In an important policy update, the Centers for Medicare & Medicaid Services has revised the Medicare Benefit Policy Manual to clarify and tighten the qualifications for speech language pathologists, delivering outpatient therapy services to Medicare beneficiaries. The change has significant implications for Clinical Fellow SLPs, especially in billing and service delivery across all outpatient settings.
As of April 18, 2025, Centers for Medicare & Medicaid Services has removed language from Section 230.3 of the manual that previously allowed clinical fellows to treat Medicare patients under supervision. The revised language now requires all SLPs billing Medicare outpatient therapy services to fully meet licensure and post graduate experience requirements, effectively disqualifying CFs with provisional licenses from treating Medicare outpatients.
To be recognized as a qualified provider of outpatient speech therapy services under original Medicare, a speech language pathologist must:
– Hold a Master’s or Doctoral degree in speech-language pathology (since Jan 1, 2015)
– Be licensed by the state in which services are provided
In states without licensure:
-Complete 350 supervised clinical hours
-Complete 9 months of supervised, full-time practice post-degree
-Pass a national examination approved by HHS
The American Speech Language Hearing Association is currently in communication with CMS. The American Speech Language Hearing Association is actively advocating for the recognition of provisional licensees as qualified Medicare providers. Their goal is to reverse the policy change and allow CF SLPs to participate in Medicare outpatient services under defined conditions.
This 2025 CMS update brings major implications for staffing, billing, and supervision in outpatient speech therapy. While it enhances clarity on qualifications, it also limits the flexibility of practices employing CFs. At Physical Therapy Now, we remain committed to delivering compliant, high-quality care and supporting our therapists through evolving regulations.
¨If you or someone you know might need physical therapy, please call us at 305-570-1633, or if you are interested in opening a Physical Therapy Franchise. Email us franchise@physicaltherapynow.com or visit our website at https://physicaltherapynow.com/franchise/
